Lifting the Lid on Food-Labelling

Food-labelling within the catering industry can represent varying roles for different food-producing businesses. For small-scale caterers who make and sell their products on the same site, there are no labelling regulations currently in place. That said, many smaller-sized caterers and food-producers proactively utilise their own labels for the benefit of their clients, customers and their own company’s reputation.<p>Meanwhile, the labelling obligations are more complex for larger caterers producing centrally and selling off-site, or supplying to other retailers. Legislation requires that ingredients and a use-by date are displayed, but additional requirements can vary depending on the local trading authority’s requirements.<p>The Food Standard Agency and the FSA Scotland recently revealed their new voluntary guidelines to warn consumers about possible allergens in food eaten in restaurants and cafes, as well as in food that is not pre-packed. Its guidelines, backed by an advice booklet which warns that ‘eating even a small bit of food’ can cause illness or death, suggests that products made with ingredients that may cause an allergic reaction should be listed on a card, label or menu.<p>However, the guidance also points out that this is not compulsory and that an alternative is to ensure that all staff are equipped to answer accurately questions from consumers about whether the food contains allergenic ingredients. The guidance stresses the importance of ensuring that employees do not guess the answer to such a question.<p>‘Allergy information is compulsory on pre-packed food,’ says Owen Warnock, Food Law expert at Eversheds law firm.<p>‘However, EU law gives member states an option to require (or not to require) written information about allergens in connection with food not packed at the time of sale (even if it is packed after the customer asks for it). The same exception applies to food eaten in restaurants and cafes. The UK took up the option not to require written labelling in those situations.’<p>According to Warnock, the new guidance was produced after extensive consultation with industry: ‘The guidance assumes that it is up to the allergic consumer to ask for information about ingredients and that there is no legal obligation on the business selling the food to volunteer that such ingredients have been used. It is reassuring that the FSA have taken this position, which we believe accords with the law.’<p>However, Warnock points out that if the consumer is given information about allergenic ingredients which is inaccurate, it is likely that the business is committing a criminal offence and may be liable to damages. <p>Meanwhile, the British Sandwich Association has produced guidelines based on legislative guides from the Ministry of Agriculture, Fisheries and Food (MAFF) and the FSA, which are designed to answer the following two questions:<p><b>When is labelling required?<b><p>Sandwiches must be fully labelled when they have been pre-packed for sale in such a way that the product cannot be altered without opening the packaging. This applies no matter from where or by whom the product is sold. Sandwiches only need to be partially labelled when they are sold non-pre-packed, or pre-packed for direct sale, by a retailer selling from the same premises in which they were packed. Sandwiches are exempted from labelling when they are sold non-pre-packed, or pre-packed for direct sale, from a catering establishment such as a fixed or mobile restaurant, canteen, club, public house or hospitals. <p><b>What labelling is required?<b><p>With certain exceptions, pre-packed sandwiches are required to be labelled with: *A name *A list of ingredients *Instructions for use (if instructions are necessary) *The name and address of the manufacturer, packer or seller *Appropriate durability indication (eg BBE) & storage conditions *The place or origin (if by omitting it, consumers might be misled) *An indication that the sandwich contains sweeteners (if present) *And, in a further development, there are signs that consumers are consciously seeking out more environmentally friendly alternatives to traditional plastic packaging.<p>Planglow, the Bristol-based supplier of branded paper-based products to the catering industry, produces labels, bags, menus and sandwich wedges, and has recently introduced an environmentally friendly alternative to frosted plastic. The Frosty Ecopaque labelling looks virtually identical to its non-biodegradable counterpart, but is actually a type of paper and can consequently be used in conjunction with the company’s biodegradable sandwich wedges.<p>Rachael Sawtell, Marketing Manager at Planglow, admits it was consumers’ heightened consciousness of social responsibility coupled with a prevailing sense of environmental awareness that led them to develop the new packaging: ‘With the increased demand for healthier lunches such as salads, wraps, fruit and sushi, and a much wider choice of food-to-go products on the market, there is now a distinct demand for biodegradable packaging for consumable items such as sandwiches and snacks,’ she says.<p>‘We wanted to develop a wrapping which would resemble traditional plastics but which would ultimately biodegrade once disposed of. The Frosty Ecopaque achieves both of these objectives and can be used with either laser or inkjet printers for easy production on site. It’s also cheaper than our standard Frosty labels, and can save customers around eight percent per box.’ As part of the labelling service they offer clients, Planglow’s graphic designers can help with individual corporate branding and production of bespoke labels for different companies and brands. The design team specialises in designing labels of all shapes and sizes, and also coordinate the branding with matching bags, packaging, menus and cups.

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As branding and presentation within the food-to-go market becomes increasingly relevant, labelling plays a key part of professional presentation and can help to convey a consistent brand image. However, some believe that in the coming years, E.U legislation will dictate higher levels of data being required on food labels, and that demand for information regarding the provenance and source of products, plus nutritional content and allergen information, will also become more significant.
Catering in Scotland unwraps the industry’s obligations to consumers…